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ACC Offers Recommendations to Improve New Worker Safety Tools Released By OSHA

WASHINGTON (Oct. 24, 2013) –In response to the release of several new Occupational Safety and Health Administration (OHSA) resources intended to help protect workers from hazardous chemicals, the American Chemistry Council (ACC) issued the following statement:

“We share OSHA’s commitment to protecting the safety of workers. The men and women of the chemical industry work hard every day to ensure the safety of our industry’s operations and to evaluate opportunities to enhance workplace safety.

“ACC and its members are proud to be a part of an industry that has safety at the core of its operations. Our companies have reduced injury and illness rates at their facilities by 79 percent since 1990, and that rate is five times lower than the U.S. manufacturing sector as a whole. These achievements are the result of industry programs such as Responsible Care®, the chemical industry’s world-class environmental, health, safety and security performance initiative, and of working closely with our partners in the federal government and in the communities in which we operate.

“ACC welcomes the launch of OSHA’s new website that will make it easier to access up-to-date information on Permissible Exposure Limits (PELs) for the workplace. We have long advocated for the development of such a resource and believe that the website is an important first step that will improve with input from users in the future. We encourage the Administration to provide a mechanism for companies to provide input regarding occupational exposure limits that companies have developed for specific chemicals and information on how such limits might apply in certain circumstances.

“We believe, however, the online tool developed by OSHA to help employers assess the relative safety of potential alternatives is too narrow. As the site acknowledges, these assessments often involve complex tradeoffs and decisions. While there may be considerable value in ensuring broad access to an array of process safety options, ACC is particularly concerned that the tool focuses only on substitution. We strongly encourage OSHA to seek stakeholder input on approaches that could offer a more comprehensive and scientifically established approach to improve worker safety, well beyond substitution.

“In particular, the site should specifically draw on the resources developed by the Center for Chemical Process Safety, Guidelines for Risk Based Process Safety and Inherently Safer Chemical Processes: A Life Cycle Approach. OSHA should be careful to communicate the limitations and strengths of the tool in a clear and concise manner. It is critical that alternatives assessment be a part of a comprehensive, thoughtful analysis by facility operators to ensure that ongoing efforts to protect worker safety under other regulatory programs, such as OSHA’s Process Safety Management Standard, are not undermined.

“ACC will continue to review these new worker safety tools and will provide comments and recommendations to OSHA to ensure these resources are as effective as possible.”